The EU Deforestation Regulation (EUDR—European Union Deforestation Regulation), Regulation (EU) 2023/1115, aims to reduce the European Union’s contribution to global deforestation and forest degradation. To this end, it imposes requirements on companies that supply certain raw materials and products made from them to the European market or export them from the EU.
The regulation applies, among other things, to the raw materials wood, cocoa, coffee, soy, palm oil, rubber, and cattle, as well as certain products made from them. Market participants are subject to specific due diligence and documentation requirements throughout the supply chain.
What does the EUDR mean for Paul Kläs and our customers?
Paul Kläs GmbH is a manufacturer of folding boxes made of solid board as well as G-flute and F-flute corrugated board. Our products are classified, among other things, under HS code 4819 2000 and therefore generally fall within the scope of the EUDR.
Since we market our packaging products as standalone products on the European market, we assume the role of a downstream operator as defined by the EUDR. As a downstream operator, we are not required under current regulations to submit our own due diligence statement (DDS) for the folding cartons we manufacture in the EUDR information system or to prepare a simplified declaration. The required due diligence for the relevant raw materials is already carried out within our upstream supply chain by the respective responsible market participants.
Since some of our direct suppliers are also classified as downstream operators, we do not always have our own DDS reference numbers on file. If a supplier is required to submit a due diligence statement as an upstream operator, the corresponding reference numbers are shared in accordance with legal requirements and documented by us. Regardless of this, we comply with the documentation and retention requirements applicable to downstream operators. This includes, in particular, the collection and retention of the necessary information regarding our direct suppliers and commercial customers. The specific role of our company must always be considered in the context of our products and activities. Should other relevant products be manufactured, traded, or exported in the future, a reassessment would be necessary.
Frequently Asked Questions About the EUDR
As a manufacturer of folding cartons, are we required to submit our own due diligence statement (DDS)?
No—our finished packaging products do not require a separate declaration of due diligence in the EUDR information system. A simplified declaration is also not applicable to our activities. We do not produce any relevant raw materials ourselves, nor do we place them on the EU market as relevant products for the first time.
What role does Paul Kläs play within the supply chain?
As part of our current business operations, we act as a downstream operator as defined by the EUDR.
A company’s specific role must always be considered in the context of the product.
How do we handle our suppliers' EUDR certificates?
To the extent that we have DDS reference numbers or other relevant EUDR documentation for the paper-based raw materials we purchase, we record and archive them as part of our supplier documentation. This allows us to trace the relevant information throughout our upstream supply chain.
This is only the case if our suppliers are not also classified as downstream operators. In that case, the DDS takes place earlier in the supply chain, which means that a DDS reference number does not need to be provided to us.
Do you have any questions? We'd be happy to meet with you in person for a consultation!
Note: The information on this page is for general guidance only and does not legal advice.